CLA News / De-risking, Re-risking & Financial Crime in this era of alternative finance by Bellina Barrow
Keywords: De-risking. Re-Risking. Financial Crime. Alternative Finance. Virtual Assets. Digital Assets. Cryptocurrency. NFTs. Financial Inclusion. AML/CFT
In the alternative finance sector, virtual assets such as cryptocurrency (1) have been in existence for several years. In cryptocurrency’s modern form, Bitcoin is said to be the first cryptocurrency created, circa 2008/2009, by a computer programmer or group of programmers under the pseudonym Satoshi Nakamoto.(2) Non-fungible tokens (NFTs) were also created some years ago. “Quantum,” was reportedly the first NFT which was sold, designed and tokenized by Kevin McKoy (in 2014) on the Namecoin blockchain, then minted on Ethereum and sold in 2021.(3)
In the traditional finance sector, correspondent banks, which service banks that operate both locally and regionally, have been terminating relationships with clients for many years. This often results in persons/ entities being unbanked and possibly resorting to “shadow banking” or unregulated alternative finance options. Virtual currencies are not prohibited, or specially legislated or regulated in Trinidad & Tobago, as the fintech industry has, as at the time of writing this article, only been legislated in relation to e-money issuers.(4) There are implications for this state of affairs in Trinidad & Tobago, against the backdrop of international AML/CFT (5) standards.
A TRINIDAD & TOBAGO SNAPSHOT
The twin-island Caribbean nation of Trinidad and Tobago is the southernmost country in the Caribbean archipelago located close to Venezuela. Trinidad and Tobago faces unique challenges, much like many of it’s Caribbean neighbours. Some of Trinidad and Tobago’s country indicators include its geographical location, role as a regional air travel and shipping hub, relative wealth and its developed financial services sector. These factors make it prone to be used by criminal groups as a trans-shipment point for drugs and other illicit goods and also susceptible to money laundering.(6)
THE FINANCIAL ACTION TASK FORCE (FATF)
The Financial Action Task Force (FATF) (7) is an independent intergovernmental body that develops and promotes policies to protect the global financial system against money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction. FATF issues recommendations called FATF 40 Recommendations, (8) of “international measures countries should take to combat money laundering and terrorist financing, as well as the financing of proliferation of weapons of mass destruction.”(9) As each country’s local circumstances and legislative landscape are unique, it is expected that these measures would be tailored to suit their particular needs.
DE-RISKING, RE-RISKING & THEIR SPILL-ON EFFECTS
For several years, banks have been severing their business relationships with clients, if the banks perceive that continuing the relationship with the client is too high of a risk for the bank to tolerate. (10) This process called de-risking, is defined by FATF as “the phenomenon of financial institutions terminating or restricting business relationships with clients or categories of clients to avoid, rather than manage, risk.” (11) This increasing trend has been particularly significant among correspondent banks who inter alia provide back-end services (such as cheque clearing, foreign exchange trading and fund transfers) on behalf of other financial institutions and are susceptible to money laundering and terrorist financing. (12)
When banking relationships are severed on account of de-risking, this leaves clients unbanked. (13) An unbanked person is defined as someone “without access to an account at any financial institution or to mobile banking services.” Financial inclusion occurs when “individuals and businesses have access to useful, sustainable, and affordable financial products and services that meet their transaction, payment, saving, credit, and insurance needs.” (World Bank, 2020). (14) De-risking therefore leads to financial exclusion (rather than financial inclusion). In 2020, the Commonwealth Fintech Toolkit highlighted that 500 million Commonwealth adults still did not have bank accounts. (15) Whether there is a subset of this figure that relates to adults who may have been subject to de-risking is not known, as that figure was not segregated along those lines in this Toolkit. De-risking also results in inter alia re-risking in that according to the Caribbean Financial Agency Task Force (CFATF) (16) , “When de-risking occurs, it drives financial transactions underground to less regulated or unregulated channels. It creates financial exclusion and there is reduced transparency.” These all lead to the increased risk of money laundering and terrorist financing. Therefore in the course of de-risking, which assists in lessening criminal activities, such as money laundering and terrorist financing, there is the potential for the transfer of high-risk clients out of the traditional financial sector to alternative financial services where it is easier, faster, and cheaper for persons to fulfill their financial needs of creating, storing, and transferring value. (17) In the alternative finance sector, cryptocurrency is presently not uniquely regulated (or legislated); nor is it outrightly banned in jurisdictions such as New Zealand and Trinidad & Tobago. (18)
VIRTUAL ASSETS AND NFTS
Virtual assets are also referred to as digital assets, one example being cryptocurrency. (19) Virtual assets are defined by FATF, as “digital representations of value that can be digitally traded, transferred or used for payment.” (20) These assets “have the potential to enable the creation and movement of value between counter parties directly, and over internet infrastructure that does not necessarily require intermediaries (like banks or correspondent banks) to do so.” (21)
In the crypto and virtual assets industry circle of today’s world, NFT definitions include or make reference to crypto/digital assets. NFTs are defined as “… a special kind of crypto asset in which each token is unique — as opposed to “fungible” assets like Bitcoin and dollar bills, which are all worth exactly the same amount. As every NFT is unique, they can be used to authenticate ownership of digital assets like artworks, recordings, and virtual real estate or pets.” (22) NFTs “are tradable digital assets that contain information that essentially says, “the person in control of this crypto wallet address is the owner of a computer file, stored in this location.” (23)
FINANCIAL CRIME IN THE ALTERNATIVE FINANCE SECTOR
Elliptic, a London-headquartered blockchain analytics firm, specializes in preventing and detecting cryptocurrency crimes by identifying illicit activity and providing actionable intelligence to agencies, published a 2022 Report entitled “NFTs and Financial Crime”. In this Report, they explored inter alia issues of money laundering, market manipulation, scams and sanctions risks with NFTs . (24) This Report indicated that: “NFTs are seen as attractive for money laundering because of their easily manipulable prices. Their price manipulable nature makes NFTs an attractive asset to conduct “trade-based money laundering” (TBML) (25), a well-known method of transferring illicit funds between accomplices while disguising them as proceeds of trade.”
A few of the key findings in this Report were that:
(i) Over $8 million of illicit funds were laundered through NFT-based platforms since 2017 – representing 0.02% of trading activity originating from known sources. However,a further $328.6 million (0.81%) originates from obfuscation services such as crypto mixers. (26) A proportion of this may reflect proceeds from illicit activity.
(ii) Over $100 million worth of NFTs were publicly reported as stolen through scams between July 2021 and July 2022, netting perpetrators $300,000 per scam on average. July 2022 saw over 4,600 NFTs stolen – the highest month on record –indicating that scams have not abated despite the crypto bear market. (27)
(iii) Tornado Cash, a US-sanctioned virtual currency mixer, was the source of $137.6 million of crypto assets processed by NFT marketplaces and the laundering tool of choice for 52% of NFT scam proceeds before being sanctioned by the Office of Foreign Assets Control (OFAC) in August 2022. (28)
Elliptic noted that the actual numbers may likely be higher than those reported since thefts are not always publicly reported.Elliptic also stated that: “while established means of laundering crypto assets through privacy coins and mixers continue to work,the rational incentive for launderers to use NFTs arguably remains low.” Later Elliptic research in March 2024, indicated that there appeared to be a limited number of large-scale mixers operating, due to law enforcement’s take downs of some of the smaller mixers. (29)
Nevertheless, there are also other crypto services (or protocols) that are being used by bad actors, separately or combined, to move, hide and cash out illicit finance including, but not limited to, privacy wallets, (30) unregulated exchanges, decentralized finance (DeFi) (31) protocols, cross-chain bridges (32) and fiat off -ramping services which convert cryptocurrency into fiat currency. (33) What this demonstrates is that the different services (or protocols) that can be used, at any point in time, by bad actors in the crypto space are dynamic and highly adaptable. (34)
FATF AND THE VIRTUAL ASSETS SECTOR
With the rise in innovative technologies, including but not limited to virtual assets, FATF took steps to cater for this growing phenomenon. As such, in 2019, FATF extended its anti-money AML/CFT measures to virtual assets (VA)and virtual asset service providers (VASPs) to prevent criminal and terrorist misuse of this sector. (35) FATF’s special recommendation – Recommendation 15 entitled “New Technologies” states:
“Countries and financial institutions should identify and assess the money laundering or terrorist financing risks that may arise in relation to (a) the development of new products and new business practices, including new delivery mechanisms, and (b) the use of new or developing technologies for both new and pre-existing products. In the case of financial institutions, such a risk assessment should take place prior to the launch of the new products, business practices or the use of new or developing technologies. They should take appropriate measures to manage and mitigate those risks. To manage and mitigate the risks emerging from virtual assets, countries should ensure that virtual asset service providers are regulated for AML/CFT purposes, and licensed or registered and subject to effective systems for monitoring and ensuring compliance with the relevant measures called for in the FATF Recommendations.”
FATF does not strictly consider NFTs to be virtual assets; as FATF generally considers them to be crypto-collectibles or unique digital assets that are not interchangeable but are used as collectibles rather than as payment or investment instruments. (36) However, FATF has noted that NFTs may fall under the Virtual Assets (VA) definition if they are to be used for payment or investment purposes in practice. FATF has stated:
“…it is important to consider the nature of the NFT and its function in practice and not what terminology or marketing terms are used. This is because the FATF Standards may cover them, regardless of the terminology. Some NFTs that on their face do not appear to constitute VAs may fall under the VA definition if they are to be used for payment or investment purposes in practice. Other NFTs are digital representations of other financial assets already covered by the FATF Standards. Such assets are therefore excluded from the FATF definition of VA, but would be covered by the FATF Standards as that type of financial asset.” (37)
FATF has observed an increase in the use of VAs (38) for terrorist financing, e.g. to finance extreme right-wing terrorism and for fundraising by ISIL and Al Qaeda. (39) With regards to virtual assets, FATF recommends that countries inter alia licence or register virtual asset service providers and supervise the sector, in the same way it supervises other financial institutions. (40)
THE LEGAL AND REGULATORY ENVIRONMENT IN TRINIDAD & TOBAGO
In Trinidad and Tobago, Section 2 of the E-Money Issuer Order, 2020 defines “Fintech” (a word blend for financial technology) as “technologically enabled financial innovation that could result in new business models, applications, processes or products with an associated material effect on financial markets and institutions and the provision of financial services.” The three (3) primary fintech regulators in Trinidad and Tobago are the Trinidad & Tobago Securities and Exchange Commission (TTSEC), Central Bank of Trinidad & Tobago (CBTT) and the Financial Intelligence Unit of Trinidad & Tobago (FIUTT). The FIUTT is the AML/CFT regulator in Trinidad and Tobago which was incorporated under the Financial Intelligence Unit of Trinidad and Tobago Act of 2009. It is responsible for inter alia implementing the AML/CFT policies of FATF. (41)
Despite the peculiar social challenges Trinidad and Tobago faces, at the time of writing this article, the three (3) fintech regulators issued a Joint Statement on virtual assets in 2019. Notwithstanding FATF Recommendation 15, this statement posits inter alia that “…virtual currencies do not have legal tender status in Trinidad and Tobago; the providers of the currencies are neither regulated nor supervised by the authorities…” More importantly, fintech legislation in Trinidad and Tobago currently only legislates e-money and e-money (42) issuers. Meanwhile, it is public knowledge that persons residing in Trinidad and Tobago do not restrict their financial activity to only e-money, as it has been reported in local newspapers that people are investing in cryptocurrency. (43)
Additionally, Chainalysis, a blockchain analytics company that provides data, software, services, and research to inter alia government agencies, financial institutions, insurance companies has also ranked Trinidad & Tobago at 129th in its 2023 Global Crypto Adoption Index. (44) The number of persons engaged in NFT activity and whether there is virtual currency mixer activity and TBML, as treated in the Elliptic 2022 Report, or any other one or combination of the other aforementioned crypto services or protocols, is unknown. This current legislative and regulatory lacuna therefore leaves the door open for criminals who engage in money laundering, terrorist financing and related financial crimes to exploit within the virtual assets space.
FATF has indicated that, “the risks posed by virtual assets and virtual assets service providers continue to increase and that the lack of regulation creates significant loopholes for criminals to exploit. This demonstrates an urgent need for jurisdictions to accelerate the implementation and enforcement of Recommendation 15 to mitigate criminal and terrorist misuse of virtual assets and virtual assets service providers.” (45)
LEGAL AND REGULATORY ADVANCEMENTS IN OTHER COUNTRIES & THE WAY FORWARD
Therefore, if lawmakers move expeditiously to have the virtual assets sector properly legislated and regulated, this would not only assist Trinidad and Tobago in achieving the standard required in Recommendation 15, but it will also assist in financial inclusion as legitimate customers who may be excluded from the traditional financial system will now have regulated alternative finance sector access including, but not limited to, access to the virtual assets sector. Various Commonwealth jurisdictions already have designated digital/virtual or crypto assets legislation and regulations e.g. in the Organisation of Eastern Caribbean States (OECS), Antigua and Barbuda and other territories have legislation related to digital assets while the British Virgin Islands has its Virtual Assets Service Providers Act, 2022. The United Kingdom has also regulated crypto assets via the Financial Services and Markets Act 2023 and the Commencement No. 1 Regulations 2023 (SI 2023/779) for said Act, which brought these assets under regulatory purview.
Trinidad and Tobago’s fintech legislation (and related regulations) does not, at the time of writing this article, provide for virtual assets, or some of the other aforementioned crypto services and protocols, and it needs to expeditiously mature and evolve beyond the E-Money Issuer Order, 2020 (and subsequent E-Money Issuer (Amendment) Order 2023) to include legislation and regulations that treat with virtual assets, as a start. This will give citizens, particularly the underbanked and unbanked, another safe option instead of them possibly resorting to “‘shadow banking’ or unregulated crypto exchanges” (46) which may be “havens for money laundering and other criminal activity.” (47) These legislative and regulatory measures will help to stem any possible developing tide of money laundering, and other financial criminal activity that may be occurring in this space as it helps to counterbalance the money laundering and terrorist financing vulnerabilities, which Trinidad and Tobago is normally at risk of, as well as those arising from de-risking and re-risking, while assisting in improving financial inclusion.
Ms. Bellina Barrow
Attorney at law
Ms Bellina Barrow is the Principal Attorney at Tenoreque Legal, a Trinidad and Tobago-based virtual legal practice which focuses on civil, corporate/commercial law (inclusive of fintech & virtual assets, cross-border and commercial arbitration disputes), sports law and other legal areas. She is admitted to legal practice in Trinidad and Tobago, Antigua and Barbuda and the British Virgin Islands.
If you wish to contact Ms. Barrow you may do so at: info@ tenorequelegalandconsulting.com or follow her on LinkedIn.
Publication Credit: This article is reproduced from the OCCBA Journal, Vol. 6 No. 1 (Jan – Jun 2024) where it was first published.
FOOTNOTES:
1. Cryptocurrency is defined “as a digital or virtual currency secured by cryptography. Most cryptocurrencies exist on decentralized networks using blockchain technology – which is a distributed ledger enforced by a disparate network of computers. Their decentralized nature of cryptocurrencies allows them to exist outside the control of governments and central authorities.” (Frankenfield, 2023) in Cryptocurrency Explained With Pros and Cons for Investment www.investopedia.com – accessed on 1st November 2023.
2. https://money.usnews.com/investing/articles/the-history-of-bitcoin > accessed on 9th February 2024.
3. Sotheby’s. “Kevin McCoy | Quantum” <https://www.sothebys.com/en/buy/auction/2021/natively-digital-a-curated-nft -sale-2/quantum > accessed on 9th February 2024.
6. United States Department of State Bureau of International Narcotics and Law Enforcement Affairs International Narcotics Control Strategic Report Volume II Money Laundering. March 2021. https://www.state.gov/wp-content/ uploads/2021/02/21-00620-INLSR-Vol2_Report-FINAL.pdf accessed on 18th November 2023.
7. https://www.fatf-gafi .org/en/publications/Fatfrecommendations/Fatf-recommendations.html accessed on 18th November 2023.
8. FATF Recommendations are recognised as the global standard for anti-money laundering (AML) and counter-terrorist f nancing (CFT). https://www.fatf-gafi .org/en/publications/Fatfrecommendations/Fatfrecommendations. html accessed on 18th November 2023.
9. https://www.fatf-gafi .org/en/publications/Fatfrecommendations/Fatf-recommendations.html accessed on 18th November 2023.
10. Liat Shetret (Director of Global Policy and Regulation, Elliptic).When Banks Leave: The Impacts of De-Risking on the Caribbean and Strategies for Ensuring Financial Access. Statement to 117th Congress (2021-2022) U.S. House Committee On Financial Services on Wednesday 14th September 2022. https://www.congress.gov/event/117th-congress/house-event/115101 accessed on 16th November 2023.
11. https://www.cfatf-gafi c.org/home/cfatf-news/449-de-risking> accessed on 18th November 2023.
12. See F.N.5
13. There are approximately 1.7 billion adults globally who remain unbanked https://thecommonwealth.org/ our-work/commonwealth-fintech-toolkit accessed on 20th November 2023.
14. https://www.worldbank.org/en/topic/financialinclusion/overview > accessed on 20th November 2023.
15. Commonwealth FinTech Toolkit (Commonwealth Secretariat 2020) https://thecommonwealth.org/ our-work/ commonwealth-fintech-toolkit accessed on 20th November 2023.
16. CFATF is a FATF-style regional organisation comprising of Caribbean territories that have agreed to implement common counter-measures against money laundering and terrorism financing. https://www. cfatf-gafi c.org/ accessed on 18th November 2023.
17. Amit Sharma (CEO & Founder, FinClusive) When Banks Leave: The Impacts of De-Risking on the Caribbean and Strategies for Ensuring Financial Access. Statement to 117th Congress (2021-2022) U.S. House Committee On Financial Services on Wednesday 14th September 2022. https://www.congress.gov/event/117th-congress/house-event/115101 accessed on 16th November 2023.
18. See https://paxos.com/2023/09/27/2023-global-digital-asset-regulation-at-a-glance and https://cointelegraph.com/learn/an-overview-of-the-cryptocurrency-regulations-in-newzealand all accessed on 3rd April 2024.
19. Cryptocurrencies are the “financial form of blockchain technology” (David L Shrier and Alex Pentland, 2022) in Global Fintech Financial Innovation in the Connected World (The MIT Press, 2022 Massachusetts Institute of Technology); See also FATF defines cryptocurrency as a decentralised convertible virtual currency that is protected by cryptography.—i.e., it incorporates principles of cryptography to implement a distributed, decentralised, secure information economy. Cryptocurrency relies on public and private keys to transfer value from one person/entity to another, and it must be cryptographically signed each time it is transferred. https://www.fatf-gafi .org/content/dam/fatf-gafi / guidance/Guidance-RBA-Virtual-Currencies.pdf.coredownload pdf accessed on 16th November 2023; See also David L Shrier and Alex Pentland. (2002). Global Fintech Financial Innovation in the Connected World (The MIT Press, 2022 Massachusetts Institute of Technology) where it is said that the individual components of blockchain technology have been around for years before Santoshi Nakomoto’s 2008 white paper and the origins of the first largescale instance, the bitcoin blockchain.
20. https://www.fatf-gafi .org/en/topics/virtual-assets.html accessed on 16th November 2023.This definition excludes digital representations of fiat currencies such as the Trinidad and Tobago Dollar.
21. Amit Sharma (CEO & Founder, FinClusive) When Banks Leave: The Impacts of De-Risking on the Caribbean and Strategies for Ensuring Financial Access. Statement to 117th Congress (2021-2022) U.S. House Committee On Financial Services on Wednesday 14th September 2022. https://www.congress.gov/event/117th-congress/houseevent/115101 accessed on 16th November 2023.
22. https://www.coinbase.com/learn/crypto-basics/what-are-nfts accessed on 9th February 2024.
23. https://www.coindesk.com/learn/what-are-nfts-and-how-do-they-work/ accessed on 9th February 2024.
25. Elliptic indicated that: “In a typical TBML scheme, two illicitly established companies initiate a fraudulent trade deal, massively over- or under-stating the price, quantity or quality of the assets being traded. A fraudulent
invoice is issued, allowing the recipient of the goods to either overpay or underpay depending on which way the funds are flowing. The result is that illicit funds are transferred and invoiced under the guise of a trade deal.”
26. Mixers are tools, which are also known as blenders, which enhance user privacy and make transactions more anonymous (Rosie Perper, 2023) in the article, “Are Crypto Mixers Legal?” https://www.coindesk.com/learn/
are-crypto-mixers-legal/ accessed on 8th February 2024. Mixing services, also known as tumblers, allow users to co-mingle their crypto assets with the aim of obscuring the original ownership and breaking the link between
sent and received funds.” in the 2022 article, “What is… a Mixer?” https://www.elliptic.co/blockchain-basics/ what-is-a-mixer? accessed on 14th May 2024.
27. A bear market is when a market experiences prolonged price declines. It typically describes a condition in which securities prices fall 20% or more from recent highs amid widespread pessimism and negative investor sentiment. (James Chen, 2022) in the article, “Bear Market Guide: Definition, Phases, Examples & How to Invest During One” https://www.investopedia.com/terms/b/bearmarket.asp accessed on 8th February 2024.
28. Reports are that, despite sanctions, Tornado Cash continues to operate via smart contracts running on decentralised blockchains, so it cannot be seized and shut down in the same manner that centralised mixers
can. Elliptic Research as at 14th March 2024 see article “North Korean hackers return to Tornado Cash despite sanctions” https://www.elliptic.co/blog/north-korean-hackers-return-to-tornado-cash-despite-sanctions accessed 25th March 2024.
29. “North Korean hackers return to Tornado Cash despite sanctions” https://www.elliptic.co/blog/northkorean- hackers-return-to-tornado-cash-despite-sanctions accessed on 25th March 2024.
30. These are non-custodial wallets which utilise wallet software that provides privacy-enhancing functionality.
31. DeFi “broadly refers to virtual asset protocols and services that purport to allow for some form of automated peer-to-peer (P2P) transactions, oft en through the use of self-executing code known as “smart contracts” based on blockchain technology.” U.S. Department of the Treasury April 2023 Illicit Finance Risk Assessment of Decentralized Finance https://home.treasury.gov/system/files/136/DeFi-Risk-Full-Review.pdf accessed on 26th March 2024 P2P transactions do not currently fall within the scope of FATF Standards, however, implementation of the Standards can still play a critical role in mitigating illicit finance risks of P2P transactions. See FATF (2023), Targeted Update on Implementation of the FATF Standards on Virtual Assets/VASPs, FATF, Paris, France, https://www.fatf-gafi .org/content/fatf-gafi /en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2023.html accessed on 26th March 2024.
32. These allow users to move funds from one blockchain to another. All of this activity happens on-chain and no centralised entity ever takes custody of the funds. Use of bridge protocols for money laundering purposes grew substantially in 2023 see The 2024 Crypto Crime Report published by Chainalysis in February 2024 accessed from www.chainalysis.com on 26th March 2024.
33. For example centralised exchanges, gambling services, crypto ATMs etc see The 2024 Crypto Crime Report published by Chainalysis in February 2024 accessed from www.chainalysis.com on 26th March 2024.
34. See The 2024 Crypto Crime Report published by Chainalysis in February 2024 accessed from www.chainalysis.com on 26th March 2024.
35. https://www.fatf-gafi .org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2023.html accessed on 18th November 2023.
36. Financial Action Task Force (FATF). Updated Guidance For a Risk-Based Approach Virtual Assets and Virtual Asset Service Providers https://www.fatf-gafi .org/content/dam/fatf-gafi /guidance/Updated- Guidance-VA-VASP.pdf.coredownload.inline.pdf accessed on 8th February 2024.
37. Ibid
38. Including anonymity-enhanced coins/cryptocurrencies (AECs).
39. FATF (2023), Targeted Update on Implementation of the FATF Standards on Virtual Assets/VASPs, FATF, Paris, France, https://www.fatf-gafi .org/content/fatf-gafi /en/publications/Fatfrecommendations/targeted
-update-virtual-assets-vasps-2023.html accessed on 26th March 2024.
40. https://fiu.gov.tt/about-us/functions-and-oversight accessed on 18th November 2023.
41. https://fiu.gov.tt/about-us/functions-and-oversight accessed on 9th February 2024.
42. E-money is monetary value represented by a claim on the issuer which is stored on an electronic device, issued on receipt of funds of an amount equal to the monetary value issued and accepted as a means of payment by a person other than the issuer. Some e.gs of e-money are e-wallets (digital wallets, mobile wallets), pre-paid cards etc. See T&T Financial Institutions Act, 2008.
43. https://trinidadexpress.com/newsextra/central-bank-on-cryptocurrencies-no-restrictions-on-pur chases/article_f63b844a-9814-11ec-b6dd-eba4fb 498a14.html#:~:text=In%20the%20joint%20public%20 advisory,be%20misused%20to%20conduct%20criminal accessed on 31st October 2023.
44. See The 2023 Geography of Cryptocurrency Report by Chainalysis published in October 2023 accessed from www.chainalysis.com on 26th March 2024.
45. https://www.fatf-gafi .org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2023.html accessed on 18th November 2023.
